Oracle general counsel and secretary Dorian Daley responded to CtW in a letter filed with the U.S. Securities and Exchange Commission on Wednesday.

"Your nine page letter purports to lay out the case why Mr. Ellison's pay package is excessive, but any thoughtful review of your letter, as we made, actually makes the opposite case - that Mr. Ellison's pay package is appropriate under the circumstances," Daley wrote. "Alarmingly, your letter includes a collection of misleading statements, snippets of media reports, and broad comparisons that distort the situation."

Oracle's board believes the company is one of the "best-managed companies in the technology sector," Daley wrote.

In addition, Ellison "remains its most critical strategic visionary" and his compensation is an "extremely low price to pay to continue to procure the leadership services of one of the world's foremost pioneers in the field of information management technology," Daley added.

There have been times when Ellison's stock option grants have "expired worthless," and other occasions when grants have "performed well -- aligning his interests directly with the interests of all Oracle shareholders," Daley wrote.

The subject of Ellison's and other Oracle executives' pay has come up on a number of previous occasions. Last year, shareholders voted against Oracle's pay practices in a non-binding measure. They will receive a similar opportunity at Oracle's upcoming shareholder meeting on Oct. 31.